Preventive detention pre-execution review is exceptional, and courts will not interfere unless a narrow exception is clearly shown.

Preventive detention orders are ordinarily not quashed before execution, because judicial review under Article 226 is limited at the pre-execution stage to narrowly defined exceptions such as lack of authority, wrong person, wrong law, vague or irrelevant grounds, or wrong purpose. The detaining authority's satisfaction remains subjective, and the Court will not reappraise the merits or sufficiency of the grounds unless one of those exceptions is clearly shown. Allegations of custodial violence, a pending inquiry, and parallel criminal proceedings did not establish any recognised exception on the facts, so the pre-execution challenge failed and the detention order was left open to execution.

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Issues: Whether a detention order under preventive detention law could be quashed at the pre-execution stage, and whether the case fell within the limited exceptions permitting such interference.

Analysis: The power of judicial review under Article 226 is wide, but in preventive detention matters it is ordinarily exercised after the order is executed and the grounds are served. Interference at the pre-execution stage is confined to exceptional situations, such as absence of authority, wrong person, wrong law, vague or irrelevant grounds, or wrong purpose. The detaining authority's satisfaction is subjective, and the Court cannot substitute its own view on the merits of the detention or the sufficiency of the grounds. The allegations of custodial violence, pending inquiry, or the existence of parallel criminal proceedings did not, on the facts, establish that the detention order was passed for a wrong purpose or that any recognised exception was made out.

Conclusion: The pre-execution challenge was not maintainable on the facts, and the High Court erred in quashing the detention order.

Final Conclusion: The detention order was restored to the extent that the authorities were left free to execute it, while the detenu retained the right to challenge it on permissible grounds after execution.

Ratio Decidendi: A preventive detention order is ordinarily not liable to be quashed before execution except in narrowly defined exceptional cases, and the Court will not interfere with the detaining authority's subjective satisfaction unless one of those exceptions is clearly established.

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